Roblox · Roblox Privacy and Cookie Policy · View original document ↗

Behavioral Advertising and Cross-Context Data Sharing

High severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Recent governance activity Roblox recorded 18 documented changes in the last 30 days.
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Document Record

What it is

Roblox uses your behavioral data and works with advertising partners who use cookies, pixels, and SDKs to serve you targeted ads based on your activity on Roblox and other websites. Users above the applicable age threshold are subject to this cross-context behavioral advertising.

This analysis describes what Roblox's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision authorizes third-party advertising partners to collect your behavioral and activity data across platforms using tracking technologies, which under California law constitutes 'sharing' personal information and triggers opt-out rights.

Recent Activity

This document changed recently

Medium May 1, 2026

The updated policy restricts personalized advertising based on age. Users under 18 will see only nonpersonalized ads on the platform, while users 18 and older may see personalized ads if they provide…

Medium Apr 23, 2026

The updated policy adds explicit language disclosing that Roblox collects persistent identifiers (IP addresses and unique device identifiers) from all users, including children, for purposes includin…

Medium Mar 8, 2026

The updated policy clarifies that parent email addresses constitute the only personal information collected from child accounts under COPPA, rather than listing persistent identifiers. The policy now…

Consumer impact (what this means for users)

Adult and teen users on Roblox may have their in-platform behavioral data and identifiers shared with advertising and analytics partners for targeted advertising; California residents have the right to opt out of this sharing under CCPA/CPRA.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Navigate to your Roblox account Privacy Settings at https://www.roblox.com/my/account#!/privacy and use the 'Do Not Sell or Share My Personal Information' option to opt out of behavioral advertising data sharing.

How other platforms handle this

Lime Medium

We may share your information with third-party advertising partners to provide you with targeted advertising. We also work with third-party analytics providers who help us understand how users interact with our Services. These third parties may use cookies, web beacons, and similar tracking technolo...

Zoom Medium

We work with third-party advertising partners to market our Products, and we share personal data with advertising networks and social media companies to serve ads. We also use analytics providers to help us understand how users interact with our Products.

Notion Medium

We may share your personal information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your personal information with busines...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may use the personal information we collect to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We work with third-party advertising partners, including advertising networks, to display ads on our platform and other sites. These partners may use cookies, pixels, SDKs, and similar tracking technologies to collect information about your activities on our services and other websites to provide you targeted advertising based on your interests. We do not engage in cross-context behavioral advertising for users we know to be under the applicable age threshold.

— Excerpt from Roblox's Roblox Privacy and Cookie Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages the CCPA and CPRA, which define 'sharing' personal information for cross-context behavioral advertising as a regulated activity requiring opt-out rights; the California Privacy Protection Agency (CPPA) and California Attorney General enforce these requirements. GDPR Article 6 requires a lawful basis for this processing, and GDPR Article 7 requires freely given, specific, informed, and unambiguous consent for advertising-related processing in the EU; the ePrivacy Directive also applies to cookie and tracking technology use in the EU. (2) GOVERNANCE EXPOSURE: High. The use of third-party pixels, SDKs, and advertising networks on a platform with a substantial minor user population creates layered compliance exposure; the policy states behavioral advertising is restricted for users below applicable age thresholds, but the technical enforcement of this restriction would be subject to regulatory scrutiny. (3) JURISDICTION FLAGS: California residents have explicit opt-out rights. EU/EEA users require consent-based mechanisms under GDPR and ePrivacy. UK users require compliance with UK GDPR and the UK ICO's guidance on cookies and advertising. Age-gating for advertising purposes is subject to heightened scrutiny under COPPA for under-13 users and under the California Age-Appropriate Design Code for users under 18. (4) CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with advertising and analytics partners must address restrictions on processing minor user data, data retention limits, and cross-context sharing obligations; procurement teams should verify that partner agreements include appropriate CCPA business purpose limitations and GDPR Article 28 data processing addenda. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should review the consent management platform (CMP) used for EU/UK users to confirm it meets the IAB TCF or equivalent standard; audit the list of third-party advertising and analytics partners receiving data; verify that the 'Do Not Sell or Share' opt-out mechanism functions correctly and applies to all relevant data flows; and assess whether SDKs embedded in the Roblox app are covered by the policy disclosures.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive data practices under Section 5 of the FTC Act, including the use of tracking technologies and behavioral advertising disclosures
    File a complaint →
  • State AG
    California's Attorney General and the California Privacy Protection Agency enforce CCPA/CPRA opt-out rights for behavioral advertising data sharing
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011400
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
65526103181ac7fe55d4543ce0b351c34dc032fe69a8add53e6f30543ae9d94a
Analysis generated
May 12, 2026 09:41 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-011400
Captured: 2026-05-12 09:41:40 UTC
SHA-256: 65526103181ac7fe…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/behavioral-advertising-and-cross-context-data-sharing/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Roblox's Behavioral Advertising and Cross-Context Data Sharing clause do?

This provision authorizes third-party advertising partners to collect your behavioral and activity data across platforms using tracking technologies, which under California law constitutes 'sharing' personal information and triggers opt-out rights.

How does this clause affect you?

Adult and teen users on Roblox may have their in-platform behavioral data and identifiers shared with advertising and analytics partners for targeted advertising; California residents have the right to opt out of this sharing under CCPA/CPRA.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.